Derek Michael Chauvin v. Minnesota

Although a slightly similar question was presented to this Court in Skilling v. U.S., 558 U.S. 945 (2009), questions remained unresolved regarding the presumption of presumed prejudice and the meaning of an “extreme case.” While Skilling identified four non-exclusive factors to presume prejudice and warrant a change of venue, issues related to community harm and juror vested interests as presumptive bias factors prior to voir dire were not addressed. A community from which the jurors will be chosen experienced catastrophic violent riots resulting from a police officer’s acts and believed that further rioting or harm to them or their families will result if they acquit the police officer as a criminal defendant. The defendant’s motion for a change of venue was denied. The questions presented are: 1. Whether catastrophic-widespread community harm and threat of harm is a presumed community bias and must be considered as a singular inquiry as an extreme case creating circumstances so inherently prejudicial that jury bias must also be presumed because jurors have a vested interest in the outcome of the case, thereby narrowing a trial court’s discretion and mandating a change of venue, without voir dire, to ensure a constitutionally fair trial under the Sixth Amendment.